Understanding Chinese Government Guidance Funds - An Analysis of Chinese-Language Sources CSET Issue Brief

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March 2021

Understanding
Chinese Government
Guidance Funds
An Analysis of Chinese-Language Sources

CSET Issue Brief

                           AUTHORS
                           Ngor Luong
                           Zachary Arnold
                           Ben Murphy
Executive Summary

China’s government is deploying massive amounts of capital in an
effort to “catch up with and surpass” the United States in advanced
technology. As part of this effort, the Chinese government has
invested financially and politically in government guidance funds
[政府引导基金], public-private investment funds that aim to both
produce financial returns and further the government’s industrial
policy goals. As of the first quarter of 2020, Chinese officials had
set up 1,741 guidance funds, with a registered target size of 11
trillion RMB (1.55 trillion USD). However, these funds had only
raised a total of 4.76 trillion RMB (672 billion USD) from private
and public sources.

While guidance funds’ ambitions are clear, their long-term
prospects for success are not. Drawing exclusively on Chinese-
language sources, this issue brief examines how guidance funds
raise and deploy capital, manage their investments, and interact
with other public and private actors. We find that many guidance
funds are poorly conceived and implemented, and that the
mechanism as a whole is often inefficient. Nonetheless, these
funds have many advantages over traditional industrial policy
mechanisms, and they are unquestionably helping mobilize money
and other resources for new businesses and emerging
technologies. The guidance fund model is no silver bullet, but it
should not be casually dismissed.

As an industrial policy tool, guidance funds have several potential
advantages:

   ● Guidance funds allow the Chinese state to leverage market
     discipline and expertise.
   ● Guidance funds offer patient capital, a critical resource for
     emerging technologies.
   ● Guidance funds can complement and amplify other
     industrial policy measures, producing robust, holistic support
     for emerging and high-tech businesses.

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In practice, however, most guidance funds fail to live up to their
ambitions, weakened by unrealistic goals, bureaucratic constraints,
incompetent management, risk aversion, and a lack of market
discipline. Our research shows that:

   ● Guidance funds often raise much less money than planned.
   ● Much of the money guidance funds raise is never actually
     invested in projects.
   ● There are too many guidance funds, leading to redundancy
     and inefficiency.
   ● Many guidance funds are poorly managed.
   ● Guidance fund capital has been wasted on nonstrategic and
     illicit activities.
   ● Guidance funds do not invest in early-stage companies as
     intended.
   ● Guidance funds often fail to attract truly private capital, and
     in some cases may even crowd private capital out of the
     market.
Even with these flaws, however, guidance funds still have
advantages over China’s traditional industrial policy mechanisms.
And today, a subset of disciplined, market-oriented guidance funds
is successfully raising money and investing in projects. These funds
are especially likely to find success when their government
sponsors are willing to tolerate some risk and allow professional
fund managers to make market-oriented decisions.

As the guidance fund model undergoes reforms, more funds may
succeed in bringing public and private capital together to advance
China’s strategic industries. To better track how the model may
evolve, we provide a set of performance indicators to apply over
the coming years.

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Table of Contents

Executive Summary ......................................................................................... 1
Introduction ........................................................................................................ 4
Guidance Funds in a Nutshell ....................................................................... 5
   How guidance funds work ........................................................................ 5
   Development and current status............................................................. 6
Guidance Funds’ Intended Benefits and Observed Weaknesses ..... 8
   Intended Benefits ......................................................................................... 9
   Observed Weaknesses ........................................................................... 14
Trends and Assessment.............................................................................. 24
Performance Indicators ............................................................................... 27
Conclusion ....................................................................................................... 31
Authors ............................................................................................................. 32
Acknowledgments ........................................................................................ 32
Appendix 1: Primary sources on guidance funds ............................... 33
      Intended Benefits ................................................................................. 33
      Observed Weaknesses ....................................................................... 41
      Trends and Assessment ..................................................................... 57
Appendix 2: Categorization of Chinese sources based on their
authoritativeness ........................................................................................... 64
Endnotes .......................................................................................................... 70

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Introduction

As part of its efforts to accelerate China’s rise as a global
technology leader, the Chinese state has used government
guidance funds [政府引导基金] to channel capital into strategic
industries. Guidance funds are public-private investment funds that
aim to both produce financial returns and further the state’s
industrial policy goals, including China’s pursuit of leadership in
artificial intelligence (AI) and other strategic and emerging
technologies. As of the first quarter of 2020, Chinese officials had
set up 1,741 guidance funds, with a cumulative registered target
size of 11 trillion RMB (1.55 trillion USD). In reality, however, these
funds had only raised a total of 4.76 trillion RMB (672 billion USD).

China’s guidance funds have drawn a great deal of attention from
policymakers, journalists, and market analysts abroad, but to date,
there has been little systematic research reported in English into
the funds’ strengths, weaknesses, and historical performances.
This paper fills this gap by drawing from hundreds of open source
Chinese-language documents, including official policies and
statements, audit reports, press coverage, interviews, research
reports, and blogs. Together, these documents reflect the diverse
views of China’s guidance fund stakeholders, from government
officials to investors, fund managers, and third-party researchers.
We use these sources to gauge guidance funds’ development and
prospects for success.

The following sections present a brief summary of the guidance
fund model, and then describe the intended benefits and observed
weaknesses of guidance funds as reflected in Chinese sources. We
then review the trends described by these sources and provide
performance indicators to track the success and failure of guidance
funds in the coming years. Throughout, we include relevant,
representative excerpts from Chinese-language documents.
Appendix 1 includes fuller excerpts, translated from Chinese;
Appendix 2 has further details on the underlying sources, their
credibility, and their authoritativeness.

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Guidance Funds in a Nutshell

How guidance funds work

Guidance funds are public-private investment funds with a dual
mandate to produce financial returns and further the state’s
industrial policy goals.1 They raise money from public and private
sources and make investments consistent with government
priorities. For example, a guidance fund might be meant to promote
a strategic industry, such as semiconductors or photonics; support
a particular type of business activity, such as startup formation or
modernizing production capacity; or attract industry to a particular
city or region.2

The fund itself is an entity formed by or at the behest of a central,
provincial, or local government agency.3 Typically, the
governmental sponsor creates the fund, sets a fundraising target,
allocates capital to part of that target directly from budget outlays,
and tries to raise the rest from other investors, whose contributions
are called “social capital” [社会资本].4 Guidance funds commonly
use the limited partnership structure common in equity finance
worldwide.5 A general partner makes investment decisions and
handles day-to-day operations, while limited partners contribute
capital and take returns (or losses).6 A guidance fund’s general
partner may be a fund management institution established by a
government agency, a state-owned investment company, or a
third-party professional fund manager.7

A guidance fund’s limited partners are often called “social capital”
investors. Most guidance funds aim to raise 70 to 80 percent of
their funding from these investors, with the public sponsor
providing the rest.8 Many commentators implicitly or explicitly
equate “social capital” with private capital–that is, capital raised
from profit-motivated investors, with no connection to the
government. In practice, though, many limited partners in guidance
funds are state-funded entities, such as state-owned enterprises
(SOEs) and state-run banks.9

Guidance funds use different investment strategies. Some invest
directly in companies or tangible projects, such as factories and
industrial parks.10 Others employ a fund-of-funds approach: they
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invest in other investment funds (including other guidance funds),
and these “sub-funds,” in turn, invest in actual projects and
businesses.11 Each guidance fund also has its own investment
conditions. For example, a fund might only invest in businesses or
sub-funds that are located in a particular province or focused on a
particular technology.12 In addition to the general partner,
bureaucrats and government-appointed expert review committees
influence the overall strategy and individual investment decisions
to varying degrees, depending on the fund.13

To entice social capital investors, guidance funds’ government
sponsors may forgo their own interest payments, assume other
investors’ losses, or provide other incentives.14 The government’s
sizable capital contributions also reduce other investors’ exposure
and signal the government’s commitment to the relevant
industries,15 in each case making participation more attractive.16

Development and current status

Chinese government guidance funds have developed in three
phases:

   ● First phase - gradual start: Central government agencies
     and a few local and provincial governments began
     establishing guidance funds in the early- to mid-2000s.17
     Numbers increased gradually into the mid-2010s, and a
     legal framework took form to regulate and promote
     subnational guidance funds.18

   ● Second phase - sharp uptick: Between 2015 and 2018,
     guidance funds saw a massive boom, especially at the local
     and provincial levels.19 Major causes included the central
     government’s promotion of the guidance fund mechanism,20
     central government plans, and policies encouraging
     investment in strategic and emerging technologies.21 The
     boom was also due to relatively loose regulation of guidance
     funds and certain guidance fund investors,22 as well as new
     restrictions on other, previously common types of local and
     provincial government spending23 along with trend-chasing
     and imitation among local bureaucrats.24

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● Third phase - slowdown: Growth fell beginning in 2018
     and 2019,25 as China’s economy slowed down,26 regulations
     tightened,27 and new local and provincial funds began facing
     the difficult realities of investing in emerging technologies
     and companies.28 Many funds reported having trouble
     raising money and finding suitable targets.29

According to Zero2IPO, a Chinese independent market research
firm, 1,741 guidance funds were operating in China as of the first
quarter of 2020.30 These funds had raised about 4.76 trillion RMB
(672 billion USD) in total, and had a cumulative target size (as
reflected in their fund registration documents) of 11 trillion RMB
(1.55 trillion USD).31 Local and provincial funds far outnumbered
national-level guidance funds, but the national-level funds were
typically several times larger in terms of target size as well as
capital raised.32 Most local and provincial funds are established
with target sizes under 10 billion RMB, while national-level funds
are typically in the 10 billion-plus range.33 Local and provincial
funds operate throughout the country, but are concentrated in the
more developed eastern and southern provinces and in existing
technology hubs such as Beijing, Shanghai, and Shenzhen.34

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Guidance Funds’ Intended Benefits and Observed
Weaknesses

To assess the benefits and weaknesses of the guidance fund
model, we reviewed hundreds of open source Chinese-language
documents, including official policies and statements, audit reports,
press coverage, interviews, research reports, and blogs. This
section collects and contextualizes insights from these documents,
with fuller, translated excerpts provided in Appendix 1. The
documents generally range from November 2014 to November
2020, corresponding roughly to the second and ongoing third
phases discussed previously.

We reviewed documents from a variety of sources. Some of these
sources, such as the People’s Daily and the National Audit Office,
are considered authoritative, meaning they reflect the Chinese
authorities’ official positions and policy priorities. It is important to
note, however, that authoritative sources may not be factually
accurate or complete.

Other sources, such as reports from state-sponsored media and
academic institutions, can be considered quasi-authoritative,
meaning they interpret official sources consistent with the
authorities’ views. Finally, we cite some non-authoritative sources,
such as reports from private consulting firms and non-state media.
These sources convey candid reactions and analyses on guidance
funds and help contextualize the governance and development of
funds. Quasi-authoritative and non-authoritative sources may be
(and often are) factually accurate, but they do not carry the same
authority as authoritative sources.

Appendix 2 has further details on our sources and their
authoritativeness.

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Intended Benefits

         Guidance funds allow the Chinese state to leverage market
         discipline and resources.

         Chinese policymakers begin to recognize the flaws of subsidy
         schemes and other traditional industrial policy tools, from
         inefficiency and waste to outright corruption.35 By bringing the
         profit motive into industrial policy, guidance funds aim to avoid
         these problems. The assumption is that professional fund
         managers with “skin in the game” and limited partners
         expecting financial returns will discipline the funds in which
         they participate.36

“To be honest, compared with the government’s past practice of directly
allocating resources to different projects and industries, this way of allocating
resources to [a] fund of funds, from there re-allocating to marketized [sub-]funds,
and from there re-allocating to specific companies and projects can be regarded
as progress or improvement.”

                  -Xu Lin, chairman of a joint U.S.-China sustainable investment
                 fund and former high-ranking Chinese development official, in a
                 2018 opinion piece in Caixin News.37

         As part of this vision, government guidance fund sponsors hope
         and expect that their profit-oriented partners will bring unique
         resources to the funds––capital above and beyond what the
         government itself can provide, clearly, but also information,
         contacts and expert judgment. One director of a city’s Finance
         Bureau observes that “because capital is the best ‘selector,’
         ‘amplifier’ and ‘accelerator’ of [a] project . . . [it] has become the
         preferred way to attract investment.”38 An expert advisor to
         major guidance funds notes that “the government is not a
         business, it lacks the people and mechanisms to screen
         projects, and it is not good at making business judgments.
         Therefore, the government began to introduce teams and

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entrust professional institutions to manage the funds while
        attracting social capital.”39

“Since last year, we have established long-term cooperative relations with
professional investment institutions. . . . These specialized investment firms . . .
[have] a large amount of high-quality resource information and projects in hand
[and] connect the guidance funds established by the government with other
[investors]. After they [announce these] investment institutions as [their]
investment partners, many project institutions will come knocking at the door
[推荐上门]. The traditional way of attracting investment can't compare with this.”

                      -Wang Jinxiang, director of Weifang City Finance Bureau in
                      Shandong province, in a 2019 interview.40

        Guidance funds offer patient capital, a critical resource for
        emerging technologies.

        With their high research and development (R&D) expenses and
        uncertain, longer-term returns, companies focused on emerging
        and fundamental technologies often struggle to raise money from
        the private sector. One state-run outlet points out that “social
        capital” investors favor areas with short investment periods and
        quick returns over nationally strategic areas that require long-term
        financial support.41 “Investment in science and technology
        [startups] will take at least five or six years of cultivation, through
        which, after going through the valley of death stage, it [will be]
        possible to see the results of development and verify the overall
        success rate,” one general manager of a leading guidance fund
        noted in a 2019 interview. “[T]he level of LP maturity and the
        degree of project recognition [i.e., investors’ familiarity with this
        type of project] is the problem, and a lot of social capital [investors]
        are not willing to focus on this field.”42 Even promising startups
        with strong initial funding may encounter the “valley of death,” an
        in-between stage of development often associated with scaling-up
        and commercialization, when capital needs outstrip revenues—
        making fundraising difficult. Without long-term investments to fill

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in the gap, innovation achievements are typically lost in the valley
        of death.43

        Guidance funds can supply stable, long-term investment capital to
        technology startups, allowing them to focus on developing high-
        quality technologies and moving from discovery to
        commercialization.44 Leaders of major guidance funds stress their
        ability to provide patient capital, support investment in strategic
        emerging industries, and help China realize its technology
        ambitions in the long run.45 “As our first strategy, we need to
        provide patient capital [耐心资本],” explains the director of a major
        Beijing guidance fund. “We are primarily positioned as a patient
        capital fund. However, patient capital is not only measured by time.
        What is the core function of patient capital? Its core function is to
        invest in S&T innovation and cover the entire process of the
        transformation of S&T achievements into commercial products,
        thereby helping innovative S&T companies cross the valley of
        death.”46

“In previous years, we have accumulated a lot of successful experience in the
operation of government guidance funds. For example, Weifang local business
Shengrui Transmission Co., Ltd. [盛瑞传动股份有限公司] successfully developed a
front-end 8-speed automatic transmission, which filled a gap in the domestic
automobile industry. However, due to capital constraints, large-scale production
encountered a bottleneck. We set up a fund specifically around this project,
injecting 13.2 million RMB (1.9 million USD) of equity investment and 100 million
RMB (15.1 million USD) of debt funding to help the enterprise build a production
line. . . . This is also a successful case of [our city fund’s strategy of] ‘looking for
projects first, setting up funds later’ [‘先找项目、后设基金’].”

                               -Wang Jinxiang, director of Weifang City Finance
                               Bureau in Shandong province, in a 2019 interview.47

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Guidance funds can complement and amplify other industrial
policy measures, producing robust, holistic support for emerging
and high-tech businesses.

Guidance funds don’t operate in a vacuum. They usually exist
alongside other industrial policy measures, such as state-
sponsored technology parks, R&D incentives, and talent
recruitment plans. “Many governments have begun to recognize
that any government's fiscal endurance has its limits,” explains one
prominent economist. “Simply relying on funding support is not
enough to bring in high-quality corporations and build industry
ecosystems. In order to attract enterprises, governments have
turned to providing supportive services, such as long-term
corporate strategy consulting, industry resource grafting, capital
engagement and other value-added services.”48

In addition to adding capital to these multifaceted schemes of
support, guidance fund institutions can help coordinate them,
making them more effective as a whole. “Government guidance
funds are often able to use their own communication channels with
relevant government departments in order to obtain various local
preferential policies and related benefits for sub-funds and
invested companies,” one independent market research firm
explains. 49 “For example, the Beijing Daxing Internet Guidance
Fund [北京大兴互联网引导基金] has set up high-quality services for
things such as location space, administrative services, policy
subsidies, resource linkage, talent recruitment and so on,” the chief
economist of a financial research institute writes, “It has also
specially formed professional industry service teams to provide
enterprises full-lifecycle service.”50 A prominent investment
consulting firm also notes that some guidance funds broker
relationships between cities—for example, “the Zhejiang Provincial
Industrial Transformation and Upgrading Fund [浙江省转型升级产
业基金] will invest 1 billion RMB (144.7 million USD) to promote
joint investment in cities, counties and social capital, and form a
provincial specialized town fund with a total scale of 10 billion
RMB (1.45 billion USD).”51

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“‘Give me a lever long enough and a fulcrum on which to place it, and I shall move
the world.’ The words of Archimedes, an ancient Greek philosopher, leap from the
pen. Is Haihe Industry Fund [a Tianjin guidance fund] not a fulcrum? It will leverage
the 478 square kilometers of land resources in Beichen [a district of Tianjin], and it
will guide investment institutions, listed companies, outstanding talents, high-
quality projects and other factors in gathering and bouncing off one another,
energizing this homeland of innovation and entrepreneurship. In the future,
Beichen's ‘industry-city integration’ [产城融合] will be brilliant.”

                           -Commentary in Tianjin Daily, an official newspaper, in
                           2020.52

         Ideally, these diverse resources form comprehensive ecosystems of
         support, fostering local economies of scale and helping emerging
         and strategic businesses take off. One market research firm points
         out that “fund towns . . . have become an important launch vehicle
         for regional financial agglomeration and financial innovation. . . . [I]n
         addition to preferential policies such as tax and rent exemptions,
         the government has also set up guidance funds and support
         operations for fund towns, which have become new tools for
         attracting local investment.”53 In conjunction with other industrial
         policy measures, another consulting firm argues, “the guidance
         fund [mechanism] can accelerate the integration of real industrial
         resources.”54 The goal is for interventions to have greater effect
         together than each would on its own. A Shenzhen fund manager
         boasts that “the great development opportunities present in
         Shenzhen are due to the environment, capital, talent, and policies
         of the city. By properly combining these factors, we have formed
         an accelerator.”55

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Observed Weaknesses

        Guidance funds often raise much less money than planned.

        New guidance funds routinely plan to raise hundreds of millions or
        even billions of yuan to invest in emerging technologies, but they
        often end up raising much less. A 2016 audit by China’s National
        Audit Office reported that “235 government investment funds had
        been set up in 16 provinces, [but] only 15% of funds in place
        actually raised social capital.”56 In 2019, one prominent research
        firm pointed to “a noticeable slowdown in the rate of launching
        [guidance funds], and . . . a large decline in the scale of
        fundraising.”57

        State-run media and independent analysts report that guidance
        funds have struggled to raise money from both public sponsors
        and the “social capital” sector, with local debt burdens, broader
        economic headwinds, and stricter regulation by the national
        government cited among the reasons.58 Analysts also note that
        private investors are reluctant to invest in the lower-return, longer-
        term projects that guidance funds are meant to favor.59

“We no longer manage government guidance funds. Many local governments
cannot come up with the money. We once signed a 10 billion RMB (1.5 billion
USD) contract [i.e., a contract to manage a 10 billion RMB guidance fund]. In the
end, it fell through because the government couldn't afford to [keep up with the
contract]. And even if the government can afford it, it's hard to raise money.”

              -An unnamed fund management company manager, as quoted in
              2018 in the China Economic Times, a state-run daily newspaper.60

        Much of the money guidance funds raise is never actually
        invested in projects.

        Guidance funds that are able to raise funds may have trouble
        finding suitable targets, so the capital is never actually invested.61 A

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2018 National Audit Office spot-check of provincial venture capital
        guidance funds found that one out of every six funds examined had
        never made any external investment [对外投资].62 To effectively
        deploy large amounts of capital, guidance funds need good
        prospects and capable personnel. Often, they have neither.63

        The government sponsors behind guidance funds also tend to be
        risk-averse, and many limit investing to certain industries or
        geographies, further narrowing the pool of potential targets. “Many
        regions have jumped on the bandwagon [跟风] of establishing
        artificial intelligence (AI) industry development funds,” one
        independent market research firm reports, “even though there are
        few local companies in the AI field. In some cases, local fund
        managers invest in projects that ‘toe the line of eligibility’ [‘擦边球’],
        in order to work around requirements related to administrative
        measures governing the investment process and to restrictions on
        which industries can be invested in.”64

“Suddenly, government guidance funds had massive inflows of funding, but how
could they spend it? The local governments seem not to have given enough
thought to this issue.”
                 -Fan Yuan, “Another Secret Behind Government Guidance
                 Funds' ‘Sleeping,’” China Economic Times, January 16, 2017.65

        There are too many guidance funds, leading to redundancy and
        inefficiency.

        Provincial and local governments have established hundreds of
        guidance funds in recent years, leading to an overcrowded and
        inefficient investment market. 66 One independent market research
        firm reports that by the first half of 2019, there were nearly 1,300
        guidance funds at the city and district levels alone. Many of these
        had overlapping policy objectives; the firm notes that “one western
        province has several special government guidance funds for
        investing in biotech and pharmaceuticals, and one city in central

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China has nearly ten government guidance funds for strategic
         emerging industries.”67

“A biotech and pharmaceutical industry cannot be developed in every province, but
every province is blindly trying to create such an industry through [guidance] funds.
Investment is cyclical. In the beginning, everybody wants in. It’s ‘national strategic
industry’ this, ‘emerging industry’ that. However, if every province is investing in
[these industries], we will have excess capacity within three years. . . . Government
guidance funds have entered an era of wild growth and we must get to the root of
the problem.”
                                    -An anonymous financial official [金融官员],
                                    speaking to the China Economic Times in 2016.68

         Meanwhile, local funds often unnecessarily duplicate the central
         government’s efforts. One government researcher notes that
         “when the central government proposed the seven strategic
         industries [七个方向]*, it did not expect each province to invest in all
         seven at once. . . . [However,] in the eyes of local governments,
         adding a new area of investment means receiving more funding
         from the central government.”69

         As government officials explained to state-run media in 2016,
         nonstrategic and duplicative funds lead to overcrowded markets,
         unproductive use of capital, and shortages of capital and
         managerial talent.70 “Competition between government guidance
         funds is becoming increasingly fierce,” an anonymous industry
         insider commented in 2017, as “thousands of government
         guidance funds at all levels and of all kinds are competing for fund
         managers. . . . Just as local governments now do to attract

         *
           As outlined in the 12th Five-Year Plan of 2010, the “seven strategic industries”
         include energy conservation and environmental protection, new-generation
         information technology, biotechnology, high-end equipment manufacturing, new
         energy, new material, and new-energy automobile.

                              Center for Security and Emerging Technology | 16
investment, they come up with a variety of preferential policies to
       attract fund managers.”71

       Many guidance funds are poorly managed.

       Local governments often rely on inexperienced, poorly incentivized
       bureaucrats to manage their guidance funds. One venture capital
       investor notices that “some local governments are keen to show off
       their accomplishments and follow the current fad [赶时髦] . . . [so
       they] give guidance fund money to new groups with no
       professional investment experience, who then gamble on various
       projects.”72 In some cases, guidance funds’ government sponsors
       [基金政府发起人] also serve as fund managers, and “still rel[y] on
       the personnel system of public institutions [事业单位] and a salary
       system similar to that of SOEs.”73 In 2016, China’s National Audit
       Office found that “among [the 235 guidance funds], 122 fund
       management companies are directly appointed by government
       departments, while 103 fund management companies have 342
       executives or investment committee members directly appointed
       by government departments.”74 As of 2019, the state still had a
       direct role in many funds’ investment decisions. 75

“31% of government guidance funds [include] government fiscal departments
[财政部门] or state-owned asset supervision departments [国资监管部门] as
observers in the investment decision-making process; for 29% of government
guidance funds, government fiscal departments or state-owned asset supervision
departments have final approval authority over investment decisions; and for 25% of
government guidance funds, government fiscal departments or state-owned asset
supervision departments occupy seats on the investment committee. This shows that
governments are still very active in the investment decision-making process of
guidance funds.”
                                   -From Zero2IPO Research Center’s 2019 report.76

       Government-affiliated fund managers are frequently inexperienced
       and politically motivated, leading to bad investment decisions. One

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private equity research center reported in 2019 that “guidance
fund management teams are uniformly weak in market acumen
and professional ability, because they are established at the behest
of government.”77 Most informed observers agree that
government-affiliated fund managers lack the market experience
and negotiation skills to invest in good projects.78

Over time, having recognized these flaws, some local governments
have begun hiring professional, market-oriented fund managers,
allocating guidance fund capital to “sub-funds” run by these
professional managers, or both. A 2018 article in the state
newspaper Securities Times reported that “many leading guidance
funds have tried to wean their management team members from
their former [bureaucratic] roles altogether . . . [and] entrust a
VC/PE institution with rich experience in local or external fund
management as a manager.”79

However, red tape and vague or unrealistic evaluation criteria can
interfere with effective management, and progress is uneven.80
According to a 2019 audit, Dalian city’s guidance fund raised 450
million RMB (64 million USD) but has yet to implement “the
effective separation of investors and managers . . . [T]he
performance appraisal system has not been established, and [the
guidance fund] has not achieved the incentive objective of linking
the performance appraisal system with the guidance fund's
management fee. . . . 11 of the 15 projects invested in by the sub-
fund failed to meet investment expectations, and 8 [of these] were
involved in court litigation at the time of withdrawal [while]
earnings are uncertain.”81

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“Because most [guidance fund] performance evaluation standard creators are
government departments, they have limited experience and lack a comprehensive
understanding of the regional economy, finance, management, statistics, and
industrial fields. Therefore, when setting performance evaluation indicators, they
will inevitably focus on preserving the value of state-owned assets, so their
performance metrics are not comprehensive or scientific . . . Some institutions use
external third-party intermediaries to conduct performance evaluations of
guidance funds, but it is difficult to find high-quality third-party institutions.”
                                 -From Zero2IPO Research Center’s 2019 report.82

      Analysts further note that there is already a market-wide shortage
      in professional investment management talent, and the state’s
      traditional management model, with its unrealistic goals and
      bureaucratic hurdles, drives many talented individuals away from
      guidance funds.83

      Guidance fund capital has been wasted on nonstrategic and illicit
      uses.

      Guidance funds are meant to invest in strategic, high-impact
      projects. But in practice, some funds have served as vehicles for
      nonstrategic, wasteful, or unauthorized activities, creating, as one
      independent market research firm wrote in 2016, “a hotbed of
      rent-seeking, corruption and other malpractices.”84 Some funds
      subsidize local companies that are already well-resourced, facilitate
      unauthorized borrowing by local governments, or use fund capital
      to guarantee social capital investors’ returns.85 For example,
      Shandong Province’s audit office reported in 2016 that nearly 2
      billion RMB (300 million USD) in guidance fund capital had been
      used “to issue entrusted loans, purchase asset management plans,
      etc.”86

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“The investments made by some industrial funds do not comply with regulations.
For example, the 90,785,800 RMB [13,429,900 USD] Kaihua County Government
Industry sub-fund [开化县政府产业子基金] was used by the fund manager to
acquire equity in listed companies on the New Over-the-Counter (OTC) Market
[新三板]. This is far from the original intention behind industrial funds.”
                  -From the Zhejiang provincial government’s 2017 audit report. 87

      New regulations and tighter budgets may now be helping reduce
      these practices, but they were widespread as recently as a few
      years ago, and still persist to some extent. Researchers note that
      some guidance funds still manage to adopt “a [loan making]
      investment model of ‘equity + debt’ [‘股 + 债’] or ‘debt disguised as
      equity’ [‘明股实债’] . . . [some funds] have, in actual operation,
      developed into ‘government subsidy funds’ [‘财政性补贴基金’] that
      use disguised government funding subsidies to reduce the risk to
      [the fund capital].”88

      Guidance funds do not invest in early-stage companies as
      intended.

      Many guidance funds are meant to support early-stage ventures,
      but they more often end up investing in mature companies. In
      2018, a major state financial news outlet reported that “6.41% [of
      guidance fund investments] are in the seed stage, about 18.69%
      are in the start-up stage, 42.30% in the expansion stage, [and]
      31.21% in the mature stage.”89 Even in areas where venture
      capital-oriented guidance funds exist, there is still little capital
      deployed. An independent market research firm found that as of
      the first half of 2019, despite accounting for 31.3 percent of all
      guidance funds, venture capital guidance funds only comprise 8
      percent of the funds’ aggregate target size.90

      Governments and state-owned fund managers have little appetite
      for the risk and uncertainty that early-stage investing entails.
      Unlike traditional venture capital investors, they demand high
      capital security and are less focused on high returns.91 One

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independent commentator notes that although guidance funds
      require their sub-funds to invest in startups, the relevant
      regulations define startups to include relatively mature companies,
      which means in practice, there is little investment in true startups.92

      On the other hand, even when guidance funds want to invest in
      early-stage companies, high-quality targets can be hard to find,
      reinforcing the bias toward mature companies. This is especially
      true for funds that focus on a particular industry or geographic
      region.93 Guidance funds are also unwilling to hire many venture
      capital and seed investment institutions as fund managers due to
      the institutions’ “short establishment times, small teams, and
      unspectacular historical performance.”94 As one prominent
      economist notes, “high-quality project financing is highly efficient,
      change in valuations is rapid, and it is difficult for government
      guidance funds to participate in it, given their current mechanisms
      with burdensome processes and long application cycles.”95

“‘Although [the] funds' balances are very large, small businesses still struggle to
get guidance funds. We've always wanted to [produce] low-sugar, low-salt, and
low-oil foods, but we haven't been able to apply for relevant funds.’ On January 10,
the head of a food company in Hangzhou told a China Times reporter in an
interview that even if he got a guidance fund investment, there would be all sorts
of problems. For example, one of his peers applied for [funding from] a local
guidance fund, but the repayment period was only two years, and his business
would have been hard-pressed to repay the loan in that narrow window of time.”

                 -Wang Xiaohui, “The 40 Billion RMB of Venture Capital Funds
                 Only Spent Over a Billion, ‘Sleeping’ Government Guidance
                 Funds,” China Times (state-supervised economic newspaper),
                 January 15, 2016.96

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Guidance funds often fail to attract truly private capital, and in
      some cases may even crowd private capital out of the market.

      In many cases, government guidance funds’ so-called “social
      capital” investors are state-backed. In one typical example, the
      Shandong provincial government noted in its 2018 audit report
      that “among the capital contributions to four [Shandong] provincial
      . . . funds, [direct] government investment and provincial state-
      owned enterprise [limited partner] contributions accounted for
      80.52%” and two funds with the size of 6 billion RMB (904 million
      USD) are entirely funded by the government and state-owned
      enterprises.97

“[Guidance funds] have not attracted much social capital. Take the National
Integrated Circuit Industry Investment Fund Co. [国家集成电路产业投资基金股份有
限公司], as an example: In addition to the Ministry of Finance (25.95%) and China
Development Bank Capital Corporation (CDB Capital) (23.07%), state-owned
enterprises such as China National Tobacco Corporation (14.42%), Beijing E-Town
International Investment and Development Co., Ltd. (7.21%) and China Mobile
Communications Corporation (7.21%) all own shares. No private capital [民营资本]
participated [in the fund’s first phase] at all.”

                -Jiang Liang, “Government Guidance Funds: A 12 Trillion RMB
                Predicament and Contradiction”, Sina News, December 15, 2018.98

      These state-owned limited partners may be less likely than private
      investors to contribute to informed, disciplined governance of the
      funds in which they participate. One former high-ranking official
      notes that state-owned investors prefer investing in guidance
      funds because even if the funds they invest in “make bad
      investments and lose money, [they] don't carry a lot of risk and
      political responsibility, because they are responding to government
      policy requirements. On the other hand, if they give money to
      market-oriented investment institutions, and investment goes
      wrong, causing losses, they have to assume a lot of responsibility.

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So, for them, the choice to fund government guidance funds aligns
with China's current market and political climate.”99

At the same time, guidance funds can crowd truly private investors
out of the market in some cases, undermining these funds’ goal of
increasing the pool of capital available for strategic industries and
potentially making the market, as a whole, less efficient. In 2014,
an academic study found that guidance funds in mature venture
capital markets “fail to guide social funding into the venture capital
field [and] materially crowd out social capital.”100 One expert
advisor to a leading national fund explains that “social capital
financing [i.e., financing from private investors] is hard to come by
right now, but getting the guidance funds' money is easier. A good
[investment] manager in this situation would be in an awkward
position [in dealing with guidance funds]. They should not take
money from a government guidance fund because it would erode
business returns. Balancing commercial returns with policy
requirements [i.e., to invest in less profitable but strategic ventures]
makes it hard for funds to excel. However, as other institutions take
increasingly larger sums from government guidance funds, they are
under a lot of pressure.”101

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Trends and Assessment

Guidance funds’ weaknesses are real. Overcapacity, diversion,
incompetent management, and excessive government intervention
are widespread, and so far, the funds have raised and deployed
much less capital than intended. In many cases, these problems are
not merely “growing pains,” but are rooted in basic issues of
institutional capacity and contradictions in the model—between
Chinese Communist Party (CCP) aims and the profit motive, and
between national visions of technological development and local,
shorter-term economic development interests.

But although guidance funds may never achieve perfect efficiency,
or live up to the sky-high ambitions of their government sponsors,
they could still contribute significantly to China’s economic and
technological development. Already, there is evidence that the
more disciplined, market-oriented funds that exist today are
successfully raising and deploying large amounts of capital.102
Some funds report high rates of return and success in fundraising
from meaningfully private third-party investors.103 Others have
demonstrated an ability to self-govern and learn from experience—
for example, by ending unsuccessful investment partnerships,
reconsidering unrealistic goals, and improving evaluation
systems.104 And many guidance funds are now run by professional
fund managers, described by both government officials and market
analysts as more resourceful and knowledgeable than the
bureaucrats they replace.105

Recent policy reforms may also strengthen the mechanism and
accelerate the deployment of capital.106 For example, recognizing
that unrealistic investment conditions have narrowed their
investment opportunities, some regionally and locally oriented
guidance funds have relaxed these restrictions. In 2017, the
director of a leading consulting firm sorted through more than 60
local guidance funds and found that “many funds still require 50
percent of their money to be invested locally, although some have
fallen to 40 percent. However, that's a bit less than the 70 percent
that was generally required a few years ago.”107 In 2020, the
Qingdao municipal government loosened some capital restrictions,

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increasing guidance funds’ capital contribution in sub-funds to as
        high as 50 percent and lowering the required rate of return for fund
        investments.108

        In other cases, guidance funds have begun to tighten selection
        standards for sub-funds and fund managers, including by showing
        preference for those with professional experience and
        understanding of local industries and projects.109 The central
        government has also strengthened regulations.110 In 2020, for
        example, the Ministry of Finance released regulatory updates
        targeting guidance funds that “are idle for a long time . . . [or] fail to
        set up or carry out business according to the agreed timeline, or the
        social capital raised is lower than the agreed minimum limit.”111

        It remains to be seen whether these reforms will make a practical
        difference. Steps toward more efficient, effective guidance fund
        practices appear localized and uneven. But even with its flaws the
        guidance fund mechanism is very likely better than the traditional
        industrial policies the Chinese government might otherwise use to
        support strategic industries, such as direct government ownership
        or cash handouts to state-favored companies.112 As the director of
        the Chinese Academy of Fiscal Sciences has observed, such
        traditional mechanisms give “[t]he government department [the]
        final say on whom to give to and whom not to give to, which is
        prone to result in phenomena such as money not being spent or
        even rent-seeking.”113

“It is more and more difficult and unsustainable to rely on preferential policies
related to land and taxation to achieve leapfrog development [跨越发展] . . .
Because capital is the best ‘selector,’ ‘amplifier’ and ‘accelerator’ of the project, not
only can it fulfill urgent requirements for funding, technology and talent, it also
completely accords with current regulatory requirements, and has become the
preferred way to attract investment. . . . The traditional way of attracting
investment cannot compare with this.”
                          -Wang Jinxiang, director of Weifang city’s Finance Bureau,
                          in a 2019 interview with the Economic Observer.114

                             Center for Security and Emerging Technology | 25
By instead incorporating the profit motive, competitive fundraising
and allocation of funds, and professional management into
industrial policy—however incompletely—China may be able to
accelerate its technological development.

                 Center for Security and Emerging Technology | 26
Performance Indicators

          The guidance fund mechanism is still developing.115 Most funds
          were established in the last five years, and are still gathering and
          deploying capital. In the coming years, guidance funds might
          accelerate the development of strategic technologies, build
          competitive domestic industries, and help China “leapfrog” its way
          to global technological leadership, particularly in AI.116 Or, the
          mechanism could founder, undermined by bureaucracy,
          unfavorable market conditions, and the model’s own internal
          contradictions. As the model continues to develop, individual funds
          and investments begin to pan out (or not), and investors, fund
          managers and regulators gain experience with the model, many
          futures are possible.

          In any event, the Chinese state continues to invest, financially and
          politically, in government guidance funds, and we expect they will
          continue to be a pillar of China’s development strategy.117 The
          United States and its allies should closely monitor these funds as
          they track China’s development as a technological superpower. To
          this end, Table 1 defines indicators of guidance funds’
          improvement or failure, derived from the research in this paper, for
          use in the coming years.

Table 1. Guidance Funds’ Future Performance Indicators

Indicator of improvement                 Indicator of failure

Fundraising

Average size of guidance funds           Guidance funds mostly remain small
increases; fewer funds smaller than      and scattered
1 billion RMB (144.7 million USD),
more funds over 5 billion RMB
(723.59 million USD)

More “social capital” participation by   State-controlled “social capital”

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investors unaffiliated with the       investors such as SOEs continue to
Chinese government                    predominate

More guidance funds attract foreign   Guidance fund investors remain
investors                             overwhelmingly Chinese nationals

Declining gap between fundraising     Funds continue to routinely raise
targets and capital actually raised   significantly less capital than
                                      intended

Investment

More investment in early-stage        Investment remains concentrated in
companies                             well-established companies

Declining gap between capital         Guidance fund capital sits idle; funds
raised and capital invested in        and sub-funds continue to report
projects                              difficulty finding suitable targets

More guidance funds report strong     Funds see low returns; governments
financial returns of more than 1.5    make up social capital investors’
times their capital contribution118   resulting losses

More guidance fund portfolio          IPOs remain the dominant exit
companies achieve exit; pathways to strategy, and relatively few portfolio
exit (e.g., listing, secondary market companies exit119
transactions, M&A) become more
accessible

Guidance fund investment strategies Investment decisions are politically
are more insulated from politics;   motivated, and professional fund
professional fund managers have     managers are overruled or sidelined
greater authority to make
independent investment decisions

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Operation and Management

Fewer new guidance funds in              Governments continue to set up
regions or sectors that already have     guidance funds in markets or
good access to finance, or that are      regions where they are not needed
unsuitable for investment

Governments eliminate funds and          Governments prop up ineffective
sub-funds that fail to raise or deploy   funds
capital

Governmental audit reports more          Audits continue to document
often confirm guidance funds’            nonstrategic guidance fund
compliance with regulations              investment, illicit practices, and idle
                                         capital

Guidance funds provide more              Transparency remains limited
information on their operations and
investments

Guidance funds collaborate on large      Efforts for vertical integration120 fail
financings                               to take off, and funds still compete
                                         for scarce resources

Subnational guidance funds become Unrealistic investment criteria
more willing to relax restrictions on related to targets’ geographies,
investment when appropriate           industries, etc. remain in place

Guidance funds are competitive for       Continuing reports of guidance fund
management and investment talent         “brain drain,” such as reports of
                                         guidance fund managers leaving for
                                         private investment firms

                            Center for Security and Emerging Technology | 29
More guidance funds use            Bureaucrats remain in charge in
professional fund managers         many cases

More guidance funds are run by top- Slow growth in funds managed by
tier, internationally active fund   top-tier professionals
managers

An effective, standardized         Vague, unrealistic evaluation criteria
management evaluation system is    are still used to measure guidance
established                        fund performance

                         Center for Security and Emerging Technology | 30
Conclusion

The Chinese government is using guidance funds to channel
massive amounts of capital into strategic industries. These funds
are meant to help the Chinese state leverage market discipline and
professional expertise, nurture emerging technology companies
with long-term capital, and strengthen a broader ecosystem of
support for high-tech businesses. In practice, however, guidance
funds suffer from unrealistic goals, excessive government
intervention, incompetent management, risk aversion, and a lack of
market discipline, and they have not raised or deployed nearly as
much money as intended.

Though imperfect, guidance funds have become a central
mechanism in Chinese industrial policy. The mechanism appears to
be improving over time, and some well-run funds are achieving
promising results. Fundamentally, guidance funds have important
advantages over the traditional policy incentives the Chinese
government might otherwise use to promote high-tech
development.

As outlined in this paper, the United States should closely monitor
the performance indicators for guidance funds’ improvements and
failures. In the long run, the success or failure of the guidance fund
mechanism will strongly shape how and to what extent China
develops cutting-edge industries, such as AI, to compete with the
United States and U.S. allies.

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Authors
Ngor Luong is a research analyst with CSET, where Zachary Arnold
is a research fellow and Ben Murphy is Chinese STEM translation
lead.

Acknowledgments
Thanks to Ashwin Acharya, Huey-Meei Chang, Shelton Fitch,
William Hannas, Joy Dantong Ma, Igor Mikolic-Torreira, Barry
Naughton, Lynne Weil, and Emily Weinstein for helpful feedback,
Jennifer Melot and Daniel Chou for technical support, and Lin Gan
for exceptional research assistance. The authors are solely
responsible for the views expressed in this report and for any
errors.

© 2021 by the Center for Security and Emerging Technology. This work
is licensed under a Creative Commons Attribution-Non Commercial 4.0
International License.

To view a copy of this license, visit
https://creativecommons.org/licenses/by-nc/4.0/.

CSET Product ID #: 20200098
Document Identifier: doi: 10.51593/20200098

                        Center for Security and Emerging Technology | 32
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